Motion,Ex Parte: Duggan vs Duggan

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                                I   Marshall E. Bluestone, Esq. (SBN 151632)
     BLUESTONE FAIRCLOTH & OLSON, LLP
 2   1825 4tb Street
     Santa Rosa, CA 95404
 3   Telephone:      707-526-4250
     Facsimile:      707-526-0347
 4   marshallSbfoleuai.corn

     Attorneys for The Duggan Family Limited Partnership,
     a California Limited Partnership



 8                                 SUPERIOR COURT OF THE STATE OF CALIFORNIA
 9                                                         COUNTY OF SONOMA

10   SEAN DUGGAN, an individual, on his own                                Case No. SCV-268905
     behalf and derivatively on behalf of the Duggan
11   Family Limited Partnership;                                           DEFENDANT'S OPPOSITION TO PLAINTIFF'S
                                                                           MOTION TO COMPEL ARBITRATION AND
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               Plaintiffs,                                                 FOR STAY OF THE PROCEEDINGS
     V.
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                                                                           Date: May 10, 2023
14   LYNN DUGGAN, an individual; and DOES                          I       Time: 3:00 p.m.
     through 25, inclusive,                                                Dept.: 17
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               Defendants,
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17             -and-

18   THE DUGGAN FAMILY LIMITED
     PARTNERSHIP, a California Limited
19   Partnership, KELLY MOFFAT, an individual,
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                Nominal Defendants.
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23             Defendants Duggan Family Limited Partnership ("DFLP") opposes Plaintiff Sean Duggan's
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     Motion (I) To Compel Arbitration and (2) For A Stay of the Proceedings. DFLP has invested time,
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     effort, and money in the proceedings before this Court. To stay this action and to begin arbitration
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     proceedings would needlessly increase the costs to the DFLP and would be an unjustified delay as the
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     trial of this matter is just two months away.
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     scv-268905 oooostt ton to ptamtilrs Motion to comocl Aribtration and to star   proceedin s
 1             Defendant DFLP joins in the oppositions filed by Defendant Kelly Moffat and Defendant Lyn

     Duggan.

     DATED: April 27, 2023.                                                   BLUESTON F             I                       LLP
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                                                                                             ars(all E. BluesYone, Attorney for The
                                                                                         ~   uggan Family Limited Partnership




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     scv-268905: oooosition to ptaintifrs Motion to compel Artbtration and to star   proceedines
                                CERTIFICATE OF SERVICE

        I am employed in Sonoma County, California. I am over the age of 18 years and not a party
to the within action. My business address is 1825 4'" Street, Santa Rosa, CA 95404. On April 27,
2023, I served the following document(s):

                DEFENDANTS'PPOSITION TO MOTION TO COMPEL
                              ARBITRA TIO/V AND FOR STA Y


by placing a true copy thereof enclosed is a sealed envelope and/or served in the manner
described below and addressed to:

Attornev for Plaintiff Sean Duggan:                 Attornev for Kellv Moffat:
Lisa C. McCurdy, Esq.                               Michael Sltklovsky, Esq.
Joy Chen, Esq.                                      50 Old Courthouse Square, 5'" Fl.
Greenberg Traurig                                   Santa Rosa, CA 95404
1840 Century Park East, Suite 1900                  (707) 545-4910 (main)
Los Angeles, CA 90067-2121                          (707) 522-8223 (direct)
Tel: 310-586-6512                                   (707) 544-0260 (fax)
Fax: 310-586-7800                                   MShklovskvSandersonzeialer.corn
mccurdvl(Ratlaw.corn
cheniovSi.tlaw.corn

Attornev for Lvnn Duaaan:
Anne Frassetto Olsen
NOLAND, HAMERLY, ETIENNE &
HOSS
A Professional Corporation
333 Salinas Street
P.O. Box 2510
Salinas, CA 93902
(831) 424-1414 ext. 210
(831) 424-1975 (fax)
aolsen(Rnheh.corn

       BY U.S. MAIL: I caused such envelope to be deposited in the mail by placing the
       envelope for collection and mailing following our ordinary business practices. I am
       readily familiar with this business'ractice for collecting and processing correspondence
       for mailing. On the same day that correspondence is placed for collection and mailing, it
       is deposited in the ordinary course of business with the United States Postal Service in a
       sealed envelope with postage fully prepaid. The name and address of each person/firm to
       whom I mailed the documents is listed above.

       BY HAND DELIVERY: I caused such envelope to be delivered by hand to the
       addressee(s) designated above.
       BY OVERNIGHT COURIER SERVICE: I caused such envelope to be delivered via
       overnight courier services to the addressee(s) designated above.


                                  CERTIFICATE OF SERVICE
       BY FACSIMILE: I caused said document(s) to be transmitted to the facsimile number(s)
       of the addressee(s) designated.
XX     BY E-MAIL:      Itransmitted electronically the listed documents(s) to the e-mail
       address(es) of the addressee(s) set forth above.

       I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct. Executed April 27, 2023, at Santa Rosa, California.




                                                        sr/all E. Bluestone




                                   CERTIFICATE OF SERVICE